Defendants Interrogatories Addressed To Plaintiff (Premises Liability Cases)

FIRST JUDICIAL DISTRICT OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF PHILADELPHIA PLAINTIFF(S) CIVIL TRIAL DIVISION Compulsory Arbitration Program v. DEFENDANT(S) COURT TERM: NO. Defendant's Interrogatories Addressed To Plaintiff Premises Liability Cases Defendant hereby makes demand that the Plaintiff(s) answer the following Interrogatories pursuant to the Pennsylvania Rules of Civil Procedure 4001 et seq. These Interrogatories must be answered as provided in Pa.R.C.P. 4006 and the Answers must be served on all other parties within thirty (30) days after the Interrogatories are deemed served. These Interrogatories are deemed to be continuing as to require the filing of Supplemental Answers promptly in the event Plaintiff(s) or Plaintiff's(s') representatives (including counsel) learn additional facts not set forth in its original Answers or discover that information provided in the Answers is erroneous. Such Supplemental Answers may be filed from time to time, but not later than thirty (30) days after such further information is received, pursuant to Pa.R.C.P. 4007.4. These Interrogatories are addressed to Plaintiff(s) as a party to this action; Plaintiff's(s') answers shall be based upon information known to Plaintiff(s) or in the possession, custody or control of Plaintiff(s), their attorney or other representative acting on their behalf whether in preparation for litigation or otherwise. These Interrogatories must be answered completely and specifically by Plaintiff(s) in writing and must be verified. The fact that investigation is continuing or that discovery is not complete shall not be used as an excuse for failure to answer each interrogatory as completely as possible. The omission of any name, fact, or other item of information from the Answers shall be deemed a representation that such name, fact, or other item was not known to Plaintiff(s), Plaintiff's(s') counsel, or other representatives at the time of service of the answers. BACKGROUND 1. Please identify if you are an individual, corporation or partnership: (a) If an individual: (1) full name (maiden name, if applicable) (2) alias(es) American LegalNet, Inc. www.FormsWorkFlow.com (3) date of birth (4) Social Security Number (5) residence and business addresses at time of the alleged accident and currently. (b) If a corporation: (1) registered corporation name (2) principal place of business (3) registered address at the time of the alleged accident and currently. (c) If a partnership: (1) registered partnership name (2) principal place of business (3) registered address at the time of the alleged accident and currently (4) the identities and residence addresses of each partner at the time of the alleged accident and currently. 2. If you are currently employed, were employed at the time of the alleged accident and/or employed for five (5) years before the accident date, state as to each time period: (a) (b) (c) (d) (e) By whom; Your stated title or position and accompanying duties and responsibilities; The length of your employment; Number of hours worked per week and/or number of days worked per week; Hourly wage and/or salary as well as supplemental wages (e.g. bonuses, overtime, etc.). American LegalNet, Inc. www.FormsWorkFlow.com 3. Did you lose time from work as a result of the alleged accident? If so, state: (a) The dates you lost from work as a result of the alleged accident; (b) The date that you returned to work; (c) The name and address of the employer where you returned to work; (d) Any change in your title or position, duties and/or responsibilities; (e) Any change in your wage, salary or supplemental wages. 4. Describe in detail any future lost wage claim and/or impairment of earning capacity you will have as a direct result of the alleged accident and the basis thereof. 5. Have you made a claim or filed a lawsuit for personal injury within the last ten (10) years? If so, state: (a) Against whom the claim or lawsuit was made including the name and address of any insurance carrier and/or parties; (b) The Commonwealth or State, County, Court, Term and Number of any lawsuits arising from that cause of action; (c) The outcome of the claim/lawsuit. 6. Have you been convicted of or pleaded guilty or nolo contendere to any crime(s) in the past ten (10) years to any crime(s) involving dishonesty or false statements as provided in Pa.R.E. 609, or has last date of confinement for said crime(s) been within the past ten (10) years? American LegalNet, Inc. www.FormsWorkFlow.com ACCIDENT INFORMATION 7. State the purpose of your presence at the location and time of the alleged accident. 8. State whether or not you were familiar with the location of the alleged accident and how often you traveled through same. 9. Did you make any complaints/reports or are you aware of any complaints/reports to anyone during the six (6) months before the alleged accident, concerning the conditions of the location where the alleged accident occurred? If so, state: (a) When; (b) Who made the complaint/report; (c) Who was the complaint/report made to; (d) The reason for the complaint/report; (e) Any action(s) taken as a result of the complaint/report; (f) The name, address and job title of the person(s) who has custody, possession and/or control of such reports or complaints. 10. If you consumed any alcoholic beverage(s), medications (prescription and/or over-thecounter) or any illicit drugs, during the forty-eight (48) hours immediately preceding the alleged accident, state: (a) The nature, amount and type of item(s) consumed; (b) The period of time over which the item(s) was/were consumed; (c) The names and addresses of any and all persons who have any knowledge as to the consumption of the aforementioned items (e.g. witnesses, physicians, etc.). American LegalNet, Inc. www.FormsWorkFlow.com 11. At the time of the alleged accident, did you suffer from any deformity, disease, ailment, disability or abnormality that may have affected your ability to walk, run, see, hear or otherwise perceive and/or navigate the location of the accident? If so, identify the condition(s) and any treating physician for that condition(s). 12. State in detail the manner in which the alleged accident occurred. 13. With reference to the alleged accident upon which this lawsuit is based, state: (a) The exact place of the alleged accident, giving the address of the location and indicating the specific part of the location at which the accident took place; (